On October 7, 2024, the U.S Department of the Treasury’s Office of Foreign Assets Control marked the one-year anniversary of the terrorist attack on Israel by designating several individuals and entities, including a sham charity, that has provided financial support to Hamas. According to OFAC, Hamas has collected up to $10 million per month since early 2024 using sham and front charities that falsely claim to help civilians in Gaza. The designees include a prominent team of financial supporters of Hamas, including the Charity Association of Solidarity with the Palestinian People, a sham charity based in Italy, and the Hamas-controlled financial institution Al-Intaj Bank. OFAC also designated Hamid Abdullah Hussein Al Ahmar (“Al Ahmar”), an international businessman and longstanding Hamas supporter, as well as nine entities that he owns, controls or directs.
The designations were imposed pursuant to Executive Order 13224, as amended, which targets terrorist groups and their supporters. As a result of these designations, all property and interests in property of the designated persons within the United States or within the possession or control of a U.S. person are blocked, and U.S. persons are generally prohibited from engaging in transactions involving a designated person. Entities owned 50 percent or more by one or more blocked persons are also blocked.
In connection with the designations, OFAC issued two general licenses under Global Terrorism Sanctions Regulations (“GTSR”), 31 CFR part 594. OFAC issued General License 30 to authorize wind down transactions with certain newly-designated entities that are owned or controlled by Al Ahmar. The transactions are authorized until November 21, 2024, provided that payments made to blocked persons are made into blocked accounts in accordance with the GTSR. OFAC issued General License 31 to authorize certain transactions related to transfer or divestment of debt or equity, or derivative contracts, to non-U.S. persons that involve Investrade Portfoy Yonetimi Anomim Sirketi (“Investrade Portfoy”), another newly-designated entity that is associated with Al Ahmar. These transactions, which are also authorized until November 21, 2024, apply to entities in which Investrade Portfoy owns a 50 percent or greater interest.
U.S. Department of Treasury Press Release | General License 30 | General License 31